In 2025, state legislatures dramatically expanded their efforts to regulate per- and polyfluoroalkyl substances (PFAS). More than 350 bills were introduced across nearly 40 states, reflecting growing concern about PFAS in water, consumer products, and waste streams. While EPA has been revising its national drinking water rules, states are moving aggressively on their own by adopting bans, disclosure requirements, and testing mandates that often exceed federal action. For regulated entities, this expanding legal complexity creates compliance challenges and heightened litigation risk. Here are a few of the more notable 2025 updates:

Rhode Island: Biosolids Testing Mandate

One of the most significant 2025 enactments is Rhode Island’s law requiring quarterly PFAS testing in biosolids before land application. Beginning Sept. 1, wastewater utilities and contractors must analyze biosolids for PFAS, with regulators empowered to deny land application if contamination is deemed excessive. The measure is among the first state laws to regulate PFAS in this waste stream so directly.

For municipalities and utilities, the law introduces new sampling protocols, documentation obligations, and potential liability if biosolids are rejected. Landowners accepting biosolids also face risk, since denial of permits or testing failures could disrupt longstanding fertilizer practices. Companies handling biosolids should be revisiting agreements now to clarify responsibilities and indemnities.

Vermont & New Mexico: Advances in PFAS Product Restrictions

Vermont’s 2025 law (H.238, Act 54) marked a bold step in restricting intentionally added PFAS in consumer products. The statute phases out categories such as cookware, textiles, cosmetics, and food packaging, with staggered effective dates to give manufacturers time to reformulate and adapt. Vermont’s approach reflects a broad “intentionally added” standard, meaning any deliberate PFAS use in a product, regardless of quantity, brings it within scope. Enforcement rests largely with the state’s attorney general and consumer-protection agencies, making Vermont one of the most aggressive jurisdictions in this space.

Just months later, New Mexico enacted HB 212, the PFAS Protection Act, creating a similarly sweeping but more detailed framework. The law bans the sale, offer for sale, and distribution of specified products containing intentionally added PFAS, beginning Jan. 1, 2027, with expansions in 2028 and a full prohibition on all consumer products by 2032, unless a “currently unavoidable use” (CUU) exemption applies. Categories covered in the early years include cookware, food packaging, dental floss, juvenile products, firefighting foam, carpets, cleaning products, cosmetics, textiles, feminine hygiene products, and ski wax.

New Mexico’s statute adds robust reporting and testing obligations. By 2027, manufacturers must disclose PFAS uses to the state environment department, including product identifiers, purpose of use, and amounts of individual PFAS by CAS number. Regulators may compel manufacturers to provide test results, and if PFAS are detected, companies must both report the product and notify downstream sellers of the prohibition. HB 212 also includes a notable exemption for certain fluoropolymers used in certain specialized industrial applications.

Together, Vermont and New Mexico illustrate the evolving state landscape with respect to regulating PFAS in products. For manufacturers and retailers, the challenge is not only eliminating PFAS from supply chains but also navigating differing compliance models.

Maine and State MCLs

Maine continues to move aggressively on drinking water standards and disclosure requirements. Its 2025 measures include new maximum contaminant levels (MCLs) and expanded reporting rules for PFAS in products. The state’s “currently unavoidable use” (CUU) process, which allows companies to petition for temporary exemptions, is emerging as a model that other jurisdictions may adopt.

For manufacturers and retailers, Maine’s deadlines require early inventory reviews and possible CUU petitions, particularly in categories like electronics or industrial goods where there are claims that PFAS alternatives are not readily available.

Practical Steps for Stakeholders

Through the remainder of 2025 and into 2026, the state legislative surge shows no signs of slowing. More states are expected to adopt PFAS-in-product restrictions, while biosolids testing requirements may spread beyond Rhode Island. Maine’s CUU process will test the feasibility of balancing public health protections with claims of limitations on PFAS alternatives. Moreover, these law highlight the challenges of a state-by-state system: regulated entities must navigate different definitions, deadlines, and exemption processes, all while federal rules remain in flux.

These new state laws also underline that waiting for uniform federal standards is no longer an option. The legal and compliance landscape is being reshaped at the state level, and proactive planning is essential to manage risk in this evolving regulatory system.